ITAT Quashes Reassessment Notice for borrowed belief without tangible material

SBS Realtors (P) Ltd. Vs ITO (ITAT Delhi) The ITAT Delhi, in the case of SBS Realtors (P) Ltd. Vs ITO, quashed the reassessment proceedings initiated against the assessee for Assessment Year (AY) 2009-10. The tribunal’s decision was based on two primary grounds: first, the reassessment was initiated for the purpose of “verification” rather than a definite belief that income had escaped assessment; and second, the Assessing Officer (AO) had no independent basis for his belief, relying mechanically on information from an Investigation Wing without any tangible material or indep...